Milliman’s midyear 2025 Multiemployer Pension Funding Study is an interim update to our annual study published in the first quarter of the year. This study updates the estimated funding status of U.S. multiemployer defined benefit (DB) pension plans as of June 30, 2025, showing the change in funding levels from December 31, 2024.

Key findings

• The aggregate market value funded percentage for multiemployer pension plans is estimated to be 100% as of June 30, 2025, up from 97% at the end of 2024.
• The estimated investment return for our simplified portfolio for the first six months of 2025 was about 6.1%.¹
• As of June 30, 2025, 122 plans have received nearly $73 billion in special financial assistance (SFA) under the American Rescue Plan Act of 2021 (ARPA), which added 9% to the aggregate funded percentage since the SFA program’s inception.

Current multiemployer pension funded percentage

Figure 1 shows that the funding shortfall for all plans improved by about $26 billion to a funding surplus of about $3 billion for the six-month period ending June 30, 2025, resulting in an increase in the aggregate funded percentage from 97% to 100%.

The amounts in Figure 1 reflect nearly $73 billion of SFA paid as of June 30, 2025, to 122 plans in accordance with ARPA and as administered by the Pension Benefit Guaranty Corporation (PBGC), including $3 billion paid so far in 2025. Without the SFA program, the aggregate funded percentage would be approximately 91%.

The liabilities in Figure 1 are projected using discount rates equal to each plan’s actuarial assumed rate of return on assets, which generally fall between 6% and 8%. The weighted average assumption for all plans is about 6.8%, unchanged from the end of 2024.

The assets in Figure 1 are based on each plan’s most recently reported market value of assets, projected forward assuming asset returns observed for a diversified portfolio typical for a U.S. multiemployer pension plan. Our simplified portfolio earned about 6.1% in the first six months of 2025.

Historical multiemployer pension funded percentage

Figure 2 shows the historical funded percentage of all multiemployer plans since the end of 2007 by the zone status on the latest Form 5500 used for the study. For example, the green line shows the historical funded percentages of plans currently in the green zone without regard to their previous zone statuses. The gray line represents plans that received SFA by June 30, 2025. The blue dotted line represents all plans combined.

In the aggregate, the current funded percentage has reached 100% for the first time in the history of our study, dating back to 2007. There are 864 plans (73% of all plans) in the green zone. The plans that are not in critical or critical and declining (C&D) status in the aggregate are better funded than they were before the 2008 global financial crisis, and continue to weather the ups and downs of the market.

As expected, plans that have received SFA have seen their funding status improve substantially. As of the date of this study, some plans that are eligible for SFA have not yet received it. Their figures will be updated in future studies.

What lies ahead?

Investment performance will remain the primary driver of most plans’ funded status, particularly since the majority of expected SFA funds have been paid. To date, 122 plans have received nearly $73 billion in SFA—almost the entire $80 billion that the PBGC originally projected for the program.

The impact of SFA will emerge over time and will be reflected in future studies as those funds are received. Eligible plans have until December 31, 2025, to submit an initial SFA application, and any revised application must be submitted by December 31, 2026. SFA is expected to be paid to plans through 2026 and possibly into 2027. Between June 30 and August 1, eight plans have either received or been approved for approximately $496 million in SFA. As of August 1, another 25 plans were under review for $3.9 billion, while 74 plans—including about 40 that have terminated—remain on the waiting list.

The SFA program was initially interpreted by PBGC to apply only to ongoing plans that met the SFA eligibility requirements. However, a recent ruling² in the U.S. Court of Appeals for the Second Circuit could significantly broaden SFA eligibility to more than 100 multiemployer plans that terminated by mass withdrawal, potentially increasing total program outlays by an additional $6 billion beyond the PBGC’s original $80 billion estimate.³ Many of these plans have already placed themselves on the waiting list, as noted above. Because terminated plans do not file actuarial information on IRS Form 5500s, this study will continue to only report on ongoing plans.

About this study

The results in this study were derived from publicly available IRS Form 5500 data filed through June 2025 for all multiemployer DB plans, numbering around 1,200 plans. Data for a limited number of plans that clearly were erroneous was modified to ensure that the results were reasonable and a sufficiently complete representation of the multiemployer universe. Such adjustments were associated with an immaterial number of plans.

Liability amounts were based on unit credit accrued liabilities reported on Schedule MB and were adjusted to the relevant measurement dates using standard actuarial approximation techniques. For this purpose, each plan’s monthly cash flow, benefit cost, and actuarial assumptions were assumed to be constant throughout the year and in the future. Projections of asset values to the measurement date reflect the use of constant cash flows and monthly index returns for a simplified portfolio composed of 42% public equity, 7% private equity, 24% investment grade debt, 4% high-yield debt, 10% real assets, 2% cash and cash equivalents, and 11% other. This asset portfolio is based on the average asset mix reported on Form 5500 Schedule R, weighted based on each plan’s reported market value of assets.

Changes to an individual plan’s data or assumptions would likely not have a significant impact on the aggregate results or the conclusions in this study.

This study reports on funded percentages and levels based on one reasonable measure of funding for these plans, where liabilities are developed using each plan’s assumed return on assets as the discount rate. Other methods of measuring liabilities and funding statuses may produce different results.

¹ Individual plans’ returns may have been higher or lower based on their asset allocations, asset classes, and management styles. For more information about the asset portfolio used for this study, see the “About this study” section.

² Bd. of Trs. of the Bakery Drivers Loc. 550 v. Pension Benefit Guaranty Corporation, No. 23-7868 (2d Cir. 2025). Justia. Retrieved August 8, 2025, from https://law.justia.com/cases/federal/appellate-courts/ca2/23-7868/23-7868-2025-04-29.html.

³ Nicholas J. Novak (June 16, 2025). Risk advisory: Appeals court ruling may cost taxpayers approximately $6 billion more in special financial assistance than originally projected. Retrieved August 8, 2025, from https://www.oversight.gov/sites/default/files/documents/reports/2025-06/SR-2025-09.pdf.